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Original Petition for Bill of Review

Original Petition for Bill of Review

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Published by A. Campbell
Wells Fargo Bank N.A. steals Ginnie Mae investment, claims for itself.
Texas Supreme Court denies right to Bill of Review showing fraud and misrepresentation. Thieves steal real property in Texas. Did Texas courts turn a blind eye? In depth explanation to courts about the MERS eScheme. Was Texas afraid to protect its citizens? Civil rights violations, Election time is near.
Wells Fargo Bank N.A. steals Ginnie Mae investment, claims for itself.
Texas Supreme Court denies right to Bill of Review showing fraud and misrepresentation. Thieves steal real property in Texas. Did Texas courts turn a blind eye? In depth explanation to courts about the MERS eScheme. Was Texas afraid to protect its citizens? Civil rights violations, Election time is near.

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Categories:Types, Business/Law
Published by: A. Campbell on Jan 06, 2014
Copyright:Attribution Non-commercial

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02/27/2014

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 NO. _________
In the Supreme Court of Texas
 ____________________________________________________
Alvie Campbell and Julie Campbell Plaintiff v. Mortgage Electronic Registration Systems, Inc., as Nominee for Lender and
Lender’s Successors and Assigns; Wells Fargo Bank, N.A.; Stephen C. Porter;
David Seybold; Ryan Bourgeois; Matthew Cunningham, and John Doe 1-100, Defendant
 ____________________________________________________
PLAINTIFF’S ORIGINAL PETITION FOR 
 BILL OF REVIEW & REQUEST FOR DISCLOSURE
 ____________________________________________________
From Cause No. 12-0549 In the Texas Supreme Court From Cause No. 03-11-00429-CV In the 3
rd
 Court of Appeals at Austin Texas From Cause No. 10-1093-C368, 368
th
 District, Williamson County, Texas
 __________________________________________________________________
Alvie Campbell 250 PR 947 Taylor, Texas 76574 (512) 796-6397 Alvie@ourlemon.com Julie Campbell 250 PR 947 Taylor, Texas 76574 (512) 791-2295 Jgc1983@hotmail.com 
 
 Plaintiffs’ Original Petition for Bill of review and Requests for Disclosure
 1
TO THE HONORABLE JUSTICES OF THE SUPREME COURT
Comes now pro se plaintiff’s, Alvie Campbell and Julia Campbell, (herein “Campbell’s)
and files this Original Petition for Bill of Review in cause number 12-0549.
1
, and will show such judgment was obtained by fraud and misrepresentation in the following;
This court has stated; “While this court has always upheld the sanctity of final
 judgments, we have also always recognized that showing the former judgment was obtained by fraud will justify a bill of review t
o set it aside.” 
, 669 SW 2d 309 - Tex: Supreme Court 1984
This court has also stated; “Extrin
sic fraud is fraud that denies a losing party the opportunity to fully litigate at trial all the rights or defenses that could have been
asserted.” See 
, 165 SW 3d 336 - Tex: Supreme Court 2005
A U.S. District Court has stated; “The Where jurisdiction depends upon domicile
that question is always open to re-examination, even upon contradictory evidence... Moreover, fraud destroys the validity of everything into which it enters. It affects fatally
even the most solemn judgments and decrees”, 
 438 F. 2d 705 - Court of Appeals, 5th Circuit 1971.
In 1952, the Texas Supreme Court stated; “Rule 166
-A, Rules of Civil Procedure,  provides for summary judgment "(c) * * The judgment sought shall be rendered forthwith
1
 See 
, 722 S.W.2d 407, 407 (Tex. 1987); see also, 
, 7 9 2 S .W. 2 d 1 5 0 , 1 5 3 (Tex.App.
 – 
Houston [1st Dist.] 1990, writ denied) (a bill of review is a separate suit in equity, brought to set aside a  judgment in the same court in an earlier suit, when the judgment in the earlier suit is final, not reviewable by appeal or by writ of error, and does not appear to be void on the face of the record).
 
 
 Plaintiffs’ Original Petition for Bill of review and Requests for Disclosure
 2
if the pleadings, depositions, and admissions on file, together with the affidavits, if any, show that
 ,
 except as to the amount of damages, there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." See
, 252 SW 2d 929 - Tex: Supreme Court 1952 The h
onorable court went on to state; “We
adopted this rule from Federal Rules of Civil Procedure rule 56, 28 U.S.C.A., and that rule has been construed as allowing
summary judgments only when there is no disputed fact issue.”
 Id The honorable court also cited from
 Kaufman v. Blackman
2
 that stated "The underlying purpose of Rule 166-A was elimination of patently unmeritorious claims or untenable defenses; not being intended to deprive litigants of their right to a full hearing on the merits of any real issue of fact." Id.
Plaintiffs’ will provide
a prima facie meritorious defense and show the court defendants acted fraudulently to
deprive plaintiffs’
; and an agent [judge] of the court did not understand nor comprehend the matter before him to be qualified to decide whether defendants were entitled to a judgment as a matter of law. By Affidavit of Joseph R.
Esquivel, Jr., the court will see how the courts were misled, and the Campbell’s were
deprived of equal due process of law. This court should grant plaintiffs Petition for Bill of Review.
2
, 239 SW 2d 422 - Tex: Court of Civil Appeals, 5th Dist. 1951
 

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